FYI
Hershberger, Wilbur (WHershbe@afrs.ars.usda.gov)
Tue, 9 Feb 1999 15:03:58 -0500
> ----------
> From: panupdates@igc.apc.org[SMTP:panupdates@igc.apc.org]
> Sent: Monday, February 08, 1999 3:34 PM
> To: panups@igc.apc.org
> Subject: PANUPS: Action alert: Risks to birds
>
> =====================================
> P A N U P S
> ***
> Pesticide Action Network
> North America
> Updates Service
> http://www.panna.org/panna/
> email panna@panna.org
> =====================================
>
> February 8, 1999
>
> Action Alert: Cotton Pesticide Poses Reproductive Risks to Birds
>
> The American Bird Conservancy's Pesticides and Birds Campaign urges
> the scientific, conservation and advocacy communities to call on the
> U.S. Environmental Protection Agency (EPA) to deny registration of
> the insecticide chlorfenapyr because of reproductive risks to birds.
> Chlorfenapyr has been characterized by EPA as "one of the most
> reproductively toxic pesticides to avian species that Environmental
> Fate and Effects Division has evaluated." Because of the agency's
> concerns regarding ecological risks, EPA's Office of Pesticide
> Programs has opened a public comment period through February 19.
>
> American Cyanamid has proposed use of chlorfenapyr (brand names
> Pirate and Alert) as an insecticide and miticide on cotton. It is
> touted as one of the most effective controls available for beet
> armyworm in chemically intensive cotton agriculture. Applications
> for use on citrus and vegetables and for termites and ants are also
> pending. Chlorfenapyr belongs to a new class of chemical called
> "pyrrole" -- never before registered by EPA. When metabolized, it
> acts on the mitochondria and disrupts production of ATP (adenosine
> triphosphate), leading to cell death and, ultimately, mortality.
>
> The following ecological concerns are detailed in the EPA risk
> assessment:
> ** In a chronic reproductive study of mallards, declines were seen
> in number of eggs laid (-41%), number of viable embryos (-44%), and
> number of normal hatchlings (-56%). A decrease in body weight of
> adult males and females (males: -14%; females -15%) was also evident
> and in females appeared in the first few weeks of exposure.
>
> ** American Cyanamid's testing shows chlorfenapyr to be persistent
> in soils, with a half-life of one or more years. Applications made
> to the same fields in consecutive years can result in a build-up in
> the soil to as much 2.5 times the annual application rate. Such
> persisting residues could contribute to levels of dietary exposure
> higher than those suggested by a single year of application.
>
> ** Chlorfenapyr residues are found in avian food items including
> weed seeds, insects and foliage. Levels of chlorfenapyr in avian
> diets may be as much as 68 times higher than the EPA threshold for
> reproductive effects, and EPA states that these toxicological
> thresholds may be exceeded for up to five weeks after initial
> application to cotton crops.
>
> ** The timing of chlorfenapyr applications coincides with critical
> reproductive events for most, if not all, of the more than 50 avian
> species that, according to American Cyanamid, are associated with
> cotton fields. Many of the tested species are showing downward
> population trends in cotton growing states.
>
> American Cyanamid has proposed numerous mitigation measures and
> restrictions for use of chlorfenapyr; however, EPA believes that
> such measures "still yield dietary exposure estimates that exceed
> chronic toxicity thresholds for birds." In addition, EPA's risk
> assessment does not include effects of ingestion of the chemical
> through preening or via drinking water, dermal exposures or
> inhalation of suspended particles. American Cyanamid also has not
> provided a field study of chlorfenapyr that specifically addresses
> avian reproductive effects.
>
> At least 13 pesticides documented as causing die-offs in migratory
> birds are currently registered for use on cotton. The American Bird
> Conservancy is concerned that the addition of another chemical with
> evidence of reproductive risks for avian species is imprudent.
>
> Send comments to the EPA by February 19 asking EPA to deny
> registration status for chlorfenapyr under Section 3 of the Federal
> Insecticide, Fungicide, and Rodenticide Act (FIFRA) given its
> reproductive toxicity for birds. In addition, call for EPA to
> discontinue the registration process for all other applications of
> chlorfenapyr. Comments that add scientific information on
> chlorfenapyr and its particular effects on avian species are
> extremely valuable, as are comments on the scientific soundness of
> EPAUs ecological risk and/or economic benefit characterizations.
>
> Include docket number OPP-34162 and send to:
> Public Information and Records Integrity Branch, Information
> Resources and Services Division (7502C), Office of Pesticides
> Programs, Environmental Protection Agency, 401 M St. SW, Washington
> DC 20460. Email can be sent to opp-docket@epamail.epa.gov as an
> ASCII attachment without special characters or encryption codes.
>
> Full text of the chlorfenapyr risk benefit assessment can be found
> at: www.epa.gov/pesticides/reg_assessment. Additional information
> can be found at the American Bird Conservancy web site:
> www.abcbirds.org
>
> Source/contact: Kelley R. Tucker, Director, Pesticides and Birds
> Campaign, American Bird Conservancy, 1250 24th St. NW, Washington,
> DC 20037; phone (202) 778-9666; fax (202) 778-9778; email
> ktucker@abcbirds.org.
>
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>
Wilbur Hershberger
WHershbe@afrs.ars.usda.gov